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Rotex Global, LLC v. Gerard Daniel Worldwide, Inc.

United States District Court, M.D. Pennsylvania

November 30, 2017

ROTEX GLOBAL, LLC, Plaintiff
v.
GERARD DANIEL WORDWIDE, INC., Defendant

          PROTECTIVE ORDER

          CHRISTOPHER C. CONNER, CHIEF JUDGE UNITED STATES DISTRICT COURT

         Plaintiff Rotex Global LLC (“Rotex”) and Defendant Gerard Daniel Worldwide Inc's (“GDW”) anticipate that discovery in this Action will require the production of documents and things and testimony containing confidential sensitive and/or proprietary information requiring protection against unrestricted disclosure and use (“Confidential Material”) In the interest of expediting discovery and limiting disputes regarding access to such information it is hereby ORDERED:

         1 Applicability. This order for the protection of Confidential Material (“Protective Order”) shall be applicable to and shall govern without limitation all documents testimony materials and information produced pursuant to Rule 26 disclosures subpoena requests for production of documents and things depositions interrogatory answers responses to requests for admissions any other discovery or production of information required or authorized by the Federal Rules of Civil Procedure court testimony or matters of evidence in connection with the Action Any third party responding to subpoenas issued in this Action or providing deposition or trial testimony in this Action may gain the protection of this Order by indicating an intention so to do and by comporting itself with the requirements and obligations of this Order

         2 Confidential Designation.

         Any party or non-party with a reasonable good faith belief that any documents materials or information produced in this case are Confidential Material may at the time of production (or in the case of testimony pursuant to the timeline set out hereinafter) and by written notice as described herein designate such documents materials or information as “Confidential” or “Highly Confidential” The information so designated collectively referred to herein as “Confidential Material ” shall thereafter be subject to the provisions of this Protective Order A party making such designation shall be referred to herein as the “Designating Party” A party receiving such Confidential Material shall be referred to herein as the “Receiving Party”

         3 Marking Documents.

         Any documents materials or information to be designated Confidential Material may be so designated either by:

(a) Furnishing a separate written notice to the counsel for the Receiving Party regarding such documents materials or information at the time of their production or upon notice at the time of production and providing designations within three business days thereafter specifically identifying the documents materials or information to be so designated (for example by identifying the document Bates number(s)) and their respective designations; or
(b) Affixing the legend “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL” on such documents materials or information prior to their production Stamping such a legend on the cover of any bound multi-page document shall designate all pages of such document unless otherwise indicated by the Designating Party

         4 Scope Of “Confidential”.

         For purposes of this Protective Order the term “Confidential” shall mean any and all documents materials or information concerning the products projects activities intellectual property marketing promotion business or financial affairs of any party to the Action acquired in the course of the party's respective work that such party believes in good faith would qualify for a protective order if sought from the Court For purposes of this Protective Order the term “Highly Confidential” shall mean any and all Confidential Material that qualifies as “Confidential” and further relates to financial information about the party future business plans pending patent applications customer information competitive information product formulation details trade secret information or proprietary computer source code

         5 Inadvertent Production.

         The inadvertent production of any Confidential Material during discovery in the Action without a “Confidential” or “Highly Confidential” designation shall be without prejudice to any claim that such material is Confidential Highly Confidential privileged in any respect or protected from discovery as trial preparation material provided that upon discovery of the omission of the “Confidential” or “Highly Confidential” designation the party producing such material promptly provides a written notice to the parties to whom the material was produced identifying the material and the designation to be applied to that material No party shall be held to have waived any rights by such inadvertent production In the event that any document material or information that is subject to a claim of privilege or that is protected from discovery as trial preparation material is inadvertently produced the party that received the document material or information shall return same together with all copies thereof to the producing party promptly after it receives a written notice from the producing party that the document material or information was produced inadvertently

         6 Disclosure Of “Confidential Information”.

         Subject to the provisions of paragraphs 7 9 and 14 below Confidential information shall be disclosed only to:

a No more than two employees officers or board members of each party to be designated as such by each party in writing prior to disclosure;
b This Court and any court to which an appeal might lie including court personnel and trial jurors;
c Outside litigation counsel of record for the non-designating parties together with their respective associate attorneys and office personnel employed or engaged in the ...

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